Temporary Import of Exhibition and Demonstration Devices: Re-export After the Event

1. Key takeaways

Bangladesh permits devices that do not yet meet the guideline requirements to be displayed at exhibitions, trade shows and demonstrations. §6.2 of the DGDA Medical Device Registration Guideline provides that no obstacle may be placed in the way of displaying such devices, subject to one condition: a clearly visible sign must state that the device cannot be marketed or put into service until it has been made to comply. Once the purpose has been served, the device may be re-exported to the country of origin.

• The exemption covers display. It does not extend to sale or to putting the device into service.
• The condition is a visible sign, and the same provision also recognises informing DGDA of the import purpose.
• Re-export to the country of origin after the event is expressly provided for, which is what makes temporary import workable.
• Devices fall under the Drug and Cosmetics Act, 2023 (Act No. 29 of 2023, in force 18 September 2023) through its definition provisions.
• Exhibition consignments and registration samples are two separate procedures, even though both involve unapproved goods.
• An order taken at a stand is a sale, and a sale falls outside the exemption.

2. Legal basis

The provision is short and does two things at once: it removes an obstacle and it imposes a condition. Reading it in full matters, because the condition is not a formality attached to the exemption but the price of it. The table below sets out each element with the wording of the guideline where the drafting itself is decisive.

Two features of the drafting are worth separating. The first is that the obligation is phrased as a restriction on the authorities, not on the exhibitor: no obstacle is to be placed in the way of display. The second is that the condition is phrased as a property of the device on the stand, which means it has to be satisfied physically at the venue and not only in the paperwork. A file that documents the import purpose but leaves the stand unmarked satisfies one limb of the provision and not the other.

3. Expert insights

Insight one: §6.2 is a two-sided clause, granting display and prohibiting sale. What it exempts is display. What it prohibits is marketing and putting into service. At a trade show a company may demonstrate, display and invite customers to examine the product, but it may not conclude a sale and may not deliver the device for use. The boundary is clear in the text and easy to blur on the floor, particularly when a customer wants to place an order at the stand. Taking the order is a commercial negotiation; delivering against it inside Bangladesh before compliance is the point at which the exemption stops applying.

Insight two: the provision offers two parallel conditions, sign or notification, and either will do. The original uses an and/or structure: a visible sign, and/or DGDA informed of the import purpose. Our recommendation is to satisfy both: a sign at the stand, and a written notification of purpose before the goods arrive. Done this way, whichever limb an official chooses to check, there is a document or a physical marker to show. The cost of doing both is trivial; the cost of having only the limb that was not asked about is a shipment held at the venue.

Insight three: the right to re-export is written into the provision, and that is what protects the exhibit. The text states plainly that the device can be re-exported to the country of origin after its purpose has been served. That gives companies a written basis for arranging temporary import and export, and for applying for bonded or temporary admission treatment where that is available. Without this provision, an exhibit could come in and then have no route out, which would make exhibitors reluctant to bring anything beyond what is already registered.

Insight four: the purpose of the import has to be documented at the point of entry, not at the point of departure. The provision refers to the purpose of the import, which means the purpose must exist and be recorded before the goods arrive. A notification written after the event describes a purpose retrospectively and reads as a justification rather than an authorisation. Preparation in advance also forces the exhibitor to settle questions it would otherwise answer at the airport: which devices, how many units, what value, and what happens to them afterwards.

4. Practical recommendations

For companies exhibiting in Bangladesh, GRZAN prepares three documents. The first is an exhibit list covering product name, model, quantity, serial number and value. The second is a letter to DGDA notifying the purpose of the import, stating the name, dates and venue of the exhibition and committing to re-export. The third is an on-site signage template in English, stating that the device cannot be marketed or put into service until it has been made to comply. With all three in place, the import, the display and the re-export each rest on a document. We also remind clients that sample NOCs and exhibition procedures are two different things: registration samples are handled under a separate route from exhibition exhibits.

• Prepare the exhibit list with serial numbers and values, and keep it consistent with the customs declaration.
• Notify DGDA in writing of the import purpose before shipment, naming the exhibition, dates and venue.
• Produce signage in English and place it where it is visible from the aisle, not behind the counter.
• Brief stand staff that orders may be discussed but that delivery in Bangladesh before compliance is not permitted.
• Schedule the re-export and retain the export declaration as evidence that the goods left the country.
• Keep the exhibition file separate from any registration sample file, since the two procedures have different bases.

5. Verification checklist

• □ The exhibit list has been prepared, including serial numbers and values
• □ The import purpose has been notified to DGDA in writing
• □ On-site signage has been produced and placed in a prominent position
• □ The sign states that the device cannot be marketed or put into service before compliance
• □ A re-export plan is scheduled, with the export declaration retained
• □ The exhibition procedure is confirmed as separate from the registration sample NOC

Regulatory information verified as of 27 October 2026.

How GRZAN can help. GRZAN provides medical device and IVD registration, quality system, authorised representative and local testing support across South Asia, including Bangladesh. Our team prepares dossiers to DGDA expectations, manages submissions and deficiency responses, and supports post-market vigilance obligations. Business enquiries: info@grzanglobal.com